During the March 8, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed the initial evaluation results. Stakeholder feedback is requested on the results and recommendations presented.
Please provide feedback by March 22.
Consumers Energy agrees with the comments provided by DTE Energy on this subject.
The Organization of MISO States’ Distributed Energy Resources Working Group (OMS DERWG) appreciates the opportunity to submit the following comments in response to MISO’s feedback request regarding both the recommendation for the geographic scope of DER-aggregations, as well as the proposed use the Dispatchable Intermittent Resource (DIR) and Energy Storage Resources (ESR) Market Participation models for the evaluation framework. This feedback does not represent the position of the OMS Board of Directors.
Evaluation Framework:
OMS DERWG is engaged and has interest in ensuring that a robust market participation option(s) is developed for DER-aggregations. At this time, with the existing constraints both in time and technology, it appears that using both the Dispatchable Intermittent Resource and Energy Storage Resources model types for the basis to begin discussion is reasonable. However, OMS DERWG would like to ensure that MISO and stakeholders look at these models comprehensively, and as Order 2222 requires, that MISO designs a participation model that can accommodate the attributes that a DER-A can provide. OMS DERWG is cognizant that designing such the ‘right’ model may not be achievable in the fourteen-month period. As we evaluate the DIR and ESR models, and discuss and learn more about DER-A's potential, it will inform how future models will need to be designed and potentially what new technological requirements MISO, distribution utilities, and states will need. OMS DERWG sees this as an iterative process, while we move toward short term compliance, we need to ensure we are learning, and staying flexible for what we may need or design in the future. Input on how a phased approach and how we track and return to this conversation may be useful for MISO to articulate to the DERTF.
Additionally, consideration on how the new Order 2222-A, and 719/719-A NOI will affect use of the product types, how expanded use of demand response aggregation, and the potential for use or streamlining of DRR 1 and DRR2 will be needed. Based on the reading of the 719/719-A NOI and Order 2222 language, we need to be aware of what changes may occur if FERC removes the state’s ability to authorize DER-A opt-outs and verify there aren’t barriers or conflicts between various market participation options for DER resource types in the DR products if there is an increase in usage of either option. These recent FERC issuances also highlight the importance of completing the ARC tariff revisions started in ER20-2591, as gaps between existing ARC processes and future DERA processes could result in unequal treatment between standalone aggregated DR versus DR included in a heterogenous DER-A.
Additionally, OMS DERWG wants again to highlight and ensure that additional supporting information is provided for MISO recommendations both to the DERTF and the MSC. MISO should provide clarity on when a recommendation is draft or final and clarity the process around providing comment. While some supporting information was provided by MISO in the slide decks, there was insufficient detail to comment on MISO's ranking and relative assessment analysis. MISO has committed to do this work moving forward. But not providing that background for the recommendation in hand today and a recommendation which MISO will likely move forward with will need substantiation by the April 2022 compliance filing (if not before). OMS DERWG requests that this assessment be provided at a near-term DERTF meeting.
Last, as noted above, OMS DERWG wants to ensure that we are evaluating and providing avenues for DER-As (whether utility managed or third party) to allow all attributes that they can provided to the market by creating workable frameworks that incent DER-As to participate. MISO needs to create market participation options around the DER-A and ensure we are not attempting to fit DER-As into existing model products for ease. It is likely a phased approach will be required, and we need to ensure we are creating paths that can be adapted later.
Geographic Scope:
OMS DERWG is supportive of the approach MISO is taking, due to the limitations currently in place due to price and power flow oscillation issues experienced by MISO’s modeling. OMS DERWG wants to ensure we are not locking into a solution, and while we may use EP-node at this time, as we learn about DER-A's and as we gain experience both with DER-A and ESRs, we may need to reevaluate the effectiveness of the EP-Node approach and understand what is technically possible and needed to broaden the geographic scope of aggregations. We would ask that MISO articulate what system needs or software is needed and its cost, to move to a broader solution.
Last, as noted above, there was insufficient detail to comment on MISO’s rankings (both what was ranked and how the options were assessed relative to each other). OMS DERWG requests that this assessment be provided at a near-term DERTF meeting.
Voltus, Inc. (“Voltus”) submits these comments following the March 8, 2021 Distributed Energy Resource Task Force meeting, where stakeholders discussed models for DER aggregation and market participation. Voltus recommends that MISO retain separate resource types for DER aggregations participating in reserve or capacity markets, and that these products are able to aggregate across pricing nodes. Voltus further recommends that MISO address the minimum size requirement for DRR1 resources.
Aggregations Across Pricing Nodes
At the March 8th meeting, MISO put forth its opinion that DER aggregations should be limited to single EP nodes. MISO expressed concern about matching price signals with system needs. Staff also explained that current dispatching logic and technology rely on pricing nodes to reflect discrete geographic locations and transmission constraints. It is clear from their set of concerns that MISO is assuming DER aggregations will be providing energy to the market. Energy pricing and dispatching are geographically constrained because they must account for transmission constraints.
Generally, Voltus supports a construct where there is alignment across the level (zonal, nodal, etc.) for three attributes:
(1) the level at which pricing is set,
(2) where dispatch decisions are made, and
(3) how aggregations can form.
Aggregations should not be limited so long as they are covered by one price and fit within the dispatch construct. By this logic, CP nodes rather than EP nodes should suffice for DERs providing energy.
The market needs more than just energy to function, though, and DERs can also provide services including ancillary services and emergency capacity. Ancillary services are dispatched and priced at the zonal level, so aggregations should be allowed to form at the zonal level. Similarly, the load modifying resources program allows some DERs to provide capacity for system-level and zonal-level emergencies. LMR pricing is based on the Planning Resource Auction, which clears at a zonal level. Aggregations should therefore form at a zonal level. (Admittedly, LMR penalties are based on LMP. Voltus’s recommendation is that penalties should instead be based on a price specified in the tariff.) MISO does not need to invent new asset types to allow DERs to provide ancillary services and emergency capacity: it only needs to open up existing asset types, including LMR and DRR1, to new types of DERs.
Voltus would also like to take this opportunity to offer to present at a future DER task force meeting about how other markets, including California ISO and New York ISO, have enabled aggregation across pricing nodes for distributed energy resources.
DRR1 Minimum Size
On slide 11 of the Evaluation Framework, the only option shown in green across all attributes is the third one: ensuring that ESR, DIR, DRR1 and DRR2 all allow for participation by assets with a minimum size of 0.1 MW. It is not defensible that MISO’s recommended approach retains a 1 MW minimum for DRRs. The only benefit of MISO’s option is ease/cost of implementation, but market access for small DERS should be given equal consideration.
Please contact me if there are any questions or concerns.
Regards,
Emily Orvis
Senior Energy Markets Manager
Voltus, Inc.
TO: MISO DISTRIBUTED ENERGY RESOURCES TASK FORCE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: FRAMEWORK INITIAL EVALUATION RESULTS
DATE: MARCH 22, 2021
In the March 8, 2021 Distributed Energy Resource Task Force (DERTF) meeting, MISO provided the initial Order 2222 evaluation framework results recommending a focus on ESR and DIR resource types for developing the DERA participation model, and a single EP Node for aggregation of participating DER resources. For now, MISO recommends focusing on Energy Storage Resource (ESR) or Dispatchable Intermittent Resource (DIR) resource types as participation models for DERs under Order 2222. Double counting was also mentioned as an area where stakeholder feedback is invited/encouraged.
In response to the related feedback request, The Entergy Operating Companies ("EOCs")[1] offer the following comments.
(1) Participation Model
The EOCs would prefer not to limit the participation models; however, MISO makes a good case for initially using ESR and/or DIR participation models for resources that will be registering to participate in the MISO Market under FERC Order 2222. Also, due to the potential proliferation of DIRs & ESRs and the unique challenges that they may bring to the distribution system, it may be best to focus initial implementation efforts on these types of resources.
The EOCs appreciate MISO’s recognition of open questions regarding the participation of price responsive demand in a DER aggregation. FERC’s broad definition of DERs raises many implementation issues.[2] With the variety and number of resources that can be in DER Aggregation, the EOCs recognize the impracticability of requiring telemetry for every asset or resource in a DER aggregation. On the other hand, the ability of numerous types of injection and demand response resources to participate in a DER aggregation means that MISO must establish metering requirements that can measure the performance of all of the resources in a DER aggregation. If the performance involves load reduction, the metering must be able to determine the effect of the dispatch on load. This effect on load is needed not only for measuring performance and settlements in MISO’s markets but also for the load-serving entity (LSE) responsible for retail loads. If the DER aggregation involves injection and load reduction resources, the metering must be able to distinguish between the two types of performance.
(2) Aggregation Level
Regarding geographical aggregation and the use of a single EPnode, the EOCs are in support of MISO’s proposal. EPnodes should most likely be established at the distribution/wholesale interface substation level, but it may also be appropriate to allow the TO and the DO some flexibility in the location of EPNodes. As MISO pointed out, EPnodes are an existing structure that are already part of the commercial model. As such, this is consistent with generation modeling as it is done today. While aggregation size may be limed by this approach, this is outweighed by the benefits it brings to the system.
The benefits of single EPnode aggregations vs a wider aggregation, such as at the LBA level, would include:
Double counting was also discussed as an area where stakeholder feedback is invited. With regard to addressing double counting concerns, there must be, at a minimum, three party verification must be built into the process and must include the Retail Service Provider, the Transmission Owner and MISO. Metering requirements must also be capable of distinguishing inputs and outputs, in addition to being able to determine the effect of the dispatch on load, if the of service performance involves load reduction.
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
[2] FERC defined DERs as “any resource located on the distribution system, any subsystem thereof or behind a customer meter.” Order 2222 at P 114. FERC also stated that DERs “may include, but are not limited to, resources that are in front of and behind the customer meter, electric storage resources, intermittent generation, distributed generation, demand response, energy efficiency, thermal storage, and electric vehicles and their supply equipment.” Id.
Environmental Sector Response:
The Environmental Sector appreciates MISO’s effort to gain feedback on the substantive aspects of Order 2222 compliance. We encourage MISO to continue presenting substantive recommendations and seeking feedback from stakeholders in an iterative, ongoing process.
General comments
In both recommendations presented at the March 8, 2021 DERTF, MISO chose the option with the least Market Efficiency and the lowest Solution Complexity/Implementation Cost. Because the color-coding for evaluation criteria is qualitative and the weighting of those evaluations is general and imprecise, it is difficult to understand how MISO is deciding on its recommendations. This is complicated by the fact that Solution Complexity and Implementation Costs often influence each other, so having a low score in one is likely to give a low score in the other. This could significantly skew recommendations heavily in favor of those two criteria when Grid Reliability and Resiliency and Market Efficiency are not obviously tied together.
MISO's recommendations thus far are erring on the side of how to ensure DERs do not disrupt the status quo rather than actively seeking to leverage the full benefits of DERs. This is contrary to FERC’s finding that without DERs MISO’s markets are unjust and unreasonable. MISO’s emphasis should be how to get the most out of DERs while maintaining reliability and benefiting the markets long term.
MISO should provide more explanation on how it is weighing the costs of benefits when deciding on its recommendations.
Please see the attached PDF for more detailed feedback on MISO's recommendations.
Sincerely,
The Environmental Sector
During the March 8, 2021 Distributed Energy Resources Task Force (DERTF) meeting, MISO discussed the initial evaluation results. Stakeholder feedback is requested on the evaluation framework and evaluation questions presented. (Issue Tracking ID#: IR070)
Environmental Sector Response:
The Environmental Sector appreciates MISO’s effort to gain feedback on the substantive aspects of Order 2222 compliance. We encourage MISO to continue presenting substantive recommendations and seeking feedback from stakeholders in an iterative, ongoing process.
General comments
In both recommendations presented at the March 8, 2021 DERTF, MISO chose the option with the least Market Efficiency and the lowest Solution Complexity/Implementation Cost. Because the color-coding for evaluation criteria is qualitative and the weighting of those evaluations is general and imprecise, it is difficult to understand how MISO is deciding on its recommendations. This is complicated by the fact that Solution Complexity and Implementation Costs often influence each other, so having a low score in one is likely to give a low score in the other. This could significantly skew recommendations heavily in favor of those two criteria when Grid Reliability and Resiliency and Market Efficiency are not obviously tied together.
MISO's recommendations thus far are erring on the side of how to ensure DERs do not disrupt the status quo rather than actively seeking to leverage the full benefits of DERs. This is contrary to FERC’s finding that without DERs MISO’s markets are unjust and unreasonable. MISO’s emphasis should be how to get the most out of DERs while maintaining reliability and benefiting the markets long term.
MISO should provide more explanation on how it is weighing the costs of benefits when deciding on its recommendations.
MISO’s recommendation of a single EP node approach for the geographic scope of aggregations
The Environmental Sector disagrees with MISO’s recommendation to limit the geographic scope of aggregations to a single node. Multi-node aggregations within a Local Balancing Area (LBA) offer alignment with MISO’s Commercial Pricing Node and Elemental Pricing Node modeling in the commercial model. Because MISO’s EP Nodes start with a LBA designation, a multi-node aggregation offers no issues for with the transmission locational impacts with which MISO is concerned.
MISO operators dispatching a Distributed Energy Resource Aggregation (DERA) at a multi-node transmission bus is similar to the aggregated Combined Cycle (CC) shown in the Local Balancing Authority 2 block in the BPM-010-r14 diagram below:
The dispatch instructions can vary by the DERA participation factors at the transmission bus. Accordingly, financial settlement can happen by weighted average LMPs across multiple EP Nodes. This approach is similar to CAISO’s process, which FERC approved.[1] Additionally, multiple technology types can participate under a multi-node aggregation model, including DR, EE, CHP, and ESR.
MISO’s recommendation to focus on DIR and ESR participation models
The Environmental Sector disagrees with MISO’s recommendation to focus on DIR and ESR participation models. Reliance solely on DIR and ESR participation models will provide the fewest options for DERs to participate in the markets and will provide the fewest benefits to the markets.
MISO’s decision on which resource types to focus on for Order 2222 compliance is premature. Slide 12 of the MISO March 8, 2021 presentation on of the Evaluation Framework shows that MISO is not prepared to make such a recommendation. Under the Risk column of the table below, MISO has listed all resources as “Under Evaluation”. MISO cannot evaluate which resources are most worth pursuing without having completed its risk evaluation.
Further, on March 18, 2021, FERC issued Order 2222-A, which removes the RERRA opt-out for demand response in heterogenous DERAs.[2] MISO must take this change into account when evaluating whether, for instance, to exclude DRR Type I and II from the recommended participation models.
Beyond MISO’s incomplete information in evaluating the various resource types, MISO’s decision to limit its focus to DIR and ESR reduces the options available to DERAs to participate in MISO’s markets.
DIR does not allow for multi-node participation, does not support resources down to 0.1 MW, and does not allow for self-commit. Additionally, as many resources are likely to be some combination of generation, demand response, storage, and any other DER that meets the definition from Order 2222, reliance on DIR will significantly reduce the numbers and kinds of resources in DERAs. This issue is exacerbated by MISO’s recent request to delay the ESR to 2025. If FERC grants this extension request, resources will have to wait more than three years following Order 2222 compliance to use one of the two products MISO is recommending.
MISO should continue its discussion with stakeholders considering this and other feedback. Further evaluation is needed to determine the breadth of participation models available for Order 2222 compliance. MISO’s emphasis should be how participation models can maximize participation by DERs.
Sincerely,
The Environmental Sector
[1] Federal Energy Regulatory Commission, California Independent System Operator Corporation, “Order Accepting Proposed Tariff Revisions Subject to Condition”, ER16-1085-000 (June 2, 2016)
[2]Federal Energy Regulatory Commission, “Order addressing arguments raised on rehearing, setting aside prior order in part, and clarifying prior order in part.” RM18-9-002 (March 18, 2021).
Xcel Energy appreciates the opportunity to provide feedback on MISO initial recommendations regarding compliance with FERC's Distributed Energy Resource Aggregation Order (O2222). We believe MISO's approach to leverage existing market structures and capabilities to enable near-term participation of DERAs is reasonable. In addition, a measured approach such as this allows the Distribution Utilities in which these DERs are located more time to develop and implement the systems and software needed to manage increasing DER penetration.
MISO Recommendations:
Xcel Energy believes this is a reasonable approach due to the dynamic nature of the distribution system. Aggregations across larger areas would require accurate distribution factors in real-time and this functionality is not currently available. As stated in the "DER Research Insights" presentation at the 3/8/21 DERTF, new tools are needed at the T&D interface to manage power flow oscillations and significant price impacts. Until these tools are developed, the best approach is to restrict DER aggregation to the smallest pricing nodes available, which is the EP Node. Aggregation limited to the EP node also mitigates the impacts to the SCUC model solution time.
Xcel Energy believes this is also a reasonable approach as leveraging these existing market participation models allows DER aggregations less than 1 MW to participate in the market without significant market system upgrades.
MGE generally supports WPPI Energy's feedback.
Thanks,
David Sapper
dsapper@ces-ltd.com
Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Distributed Energy Resource Task Force (“DERTF”) on the DRAFT Initial Evaluation Results associated with the Order 2222 Evaluation Framework that MISO presented at the March 8, 2021 meeting of the DERTF. AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy resources. AEMA members support the beneficial incorporation of distributed energy resources (“DER” or “DERs”), including advanced energy management solutions, into wholesale markets as a means to achieving electricity cost savings for consumers, contributing to system reliability, and ensuring balanced price formation. These comments represent the collective consensus of AEMA as an organization, although they do not necessarily represent the individual positions of the full diversity of AEMA member companies.
AEMA recognizes that MISO has only presented the initial evaluation as a starting point for discussion and appreciates the opportunity to provide feedback on the evaluation results for potential solutions related to MISO’s compliance approach to FERC Order 2222 from the March 8th meeting of the DERTF.[2]
On the specific recommendations presented by MISO, AEMA would offer the following feedback:
Additionally, AEMA would suggest that MISO should reach out to stakeholders for compiling the list of options to be considered in the evaluation. For example, MISO looked at four options for “focus of participation models,” but did not solicit feedback for other options relative to this issue. Creation of a new participation model that fits the unique capabilities of aggregated homogeneous DER aggregations should also be an option under consideration, but it is not listed under the options considered.
AEMA recognizes that widespread aggregation of large numbers of resources across broad geographic regions may be problematic for MISO operations and not “technically feasible.” However, AEMA would request that MISO explore the definition of “technically feasible” and look beyond what is currently feasible or feasible without modifications. For example, is it possible to allow aggregations across multiple nodes at a limited scope? AEMA would suggest that MISO should allow aggregation of some level of participation (perhaps 5 MW’s of combined DER) over multiple EP Nodes within a defined MISO Zone or Balancing Area. Aggregations in excess of some defined limit (such as 5 MWs) might be limited to a single EP node, but in small amounts, multi-zone aggregations should be allowed. This provision would allow DERAs to combine resources across geographic areas that are less densely populated in an efficient manner and support the MISO market.
Of particular concern to AEMA is that MISO, in its simplified evaluation framework, has failed to demonstrate that aggregation across limited nodes is not technically feasible as directed by FERC in Order 2222.[4]
If MISO has concerns about congestion and price differentials in situations of combined resources across multiple nodes, then MISO could examine the specific geographic situation and historic operation of the region for DERA proposals to identify if there are potential challenges in the specific area. This would allow MISO to minimize impacts to the system in certain areas of high congestion or limited transmission capability.
MISO should consider different geographic scopes of aggregation depending on the type of service being provided as well. For example, capacity or spinning reserves could be aggregated differently than resources providing energy or regulation. This is made even more relevant since MISO dispatches spinning reserves and capacity resources pro rata today.
Aggregation of resources and aggregation of performance should be separated to allow the aggregator to call upon multiple resources (and technologies) to meet MISO dispatch instructions.
Ultimately, AEMA recommends that MISO expand the narrow scope of its recommendation to allow additional aggregation options.
While the MISO models for DIR and ESR may work well for resources that are homogeneous and of a specific type, they are not be the best models for aggregated DER that can be of multiple technologies. The same issue exists for Aggregators of Retail Customers, where MISO defines ARCs only in terms of aggregations of LMRs or DRRs.[5]
Particular concerns include the fact that the DIR option does not allow for the offering of the full suite of Energy and Ancillary Services to the MISO market and that the ESR option may not be an option for many years, given the latest request from MISO to extend implementation of ESRs to 2025.
Ultimately, AEMA would encourage MISO to consider creating a new DER participation model that accommodates DER that is capable of either on-site load reduction and/or injection of electricity to the grid, which are within the physical and operational characteristics of distributed energy resource aggregations. FERC Order 2222 requires that “each RTO/ISO incorporate appropriate bidding parameters into its participation models as necessary to account for the physical and operational characteristics of distributed energy resource aggregations.”[6] The recommended solution by MISO does not meet that requirement. In fact, none of the current MISO models fit this type of aggregated response.
This new resource type should be able to participate in both Day-Ahead and Real-Time Energy Markets where the DER is treated as a single resource with injections compensated as generation and load off-sets compensated as demand response. The risk of simply adapting existing participation models that have been developed for homogeneous resource types, is that the participation model could become a barrier to participation and not capture the full capability of an aggregated heterogeneous aggregation of DER.
DERs should have the option to enroll Behind-the-Meter (BTM) resources as if they were front-of-the meter (through direct metering and settlement of the DER) and not under existing DR models, particularly where DRR Type II requires an associated load zone and does not allow net injections to be offered in the DA market.
If MISO moves forward with a focus on DIR and ESR models, then MISO should overhaul those models to capture all options related to the full potential of DER aggregation capabilities including those of multi-technology aggregation, load reductions, and energy injections.
AEMA appreciates MISO’s consideration of these comments as part of the Order 2222 compliance approach being discussed in the DERTF. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to meet with AEMA members.
Respectfully Submitted,
Katherine Hamilton
Executive Director, Advanced Energy Management Alliance
Katherine@aem-alliance.org
202-524-8832
or
DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052
[1] For additional information, see AEMA website: http://aem-alliance.org
[2] https://cdn.misoenergy.org/20210308%20DERTF%20Item%2006%20Survey%20Results%20Presentation528118.pdf
[3] Order No. 2222, 172 FERC ¶ 61,247 at P 188. “Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators”
[4] Order No. 2222, 172 FERC ¶ 61,247 at P 204.
[5] MISO Demand Response Business Practices Manual (BPM-026-r5); p. 26. https://cdn.misoenergy.org/BPM%20026%20-%20Demand%20Response49596.zip
[6] Order No. 2222, 172 FERC ¶ 61,247 at P 227.
As part of MISO’s compliance with FERC’s Distributed Energy Resource Aggregation order (O2222), WPPI supports MISO’s proposal to:
(1.) Allow for aggregation behind a single EPNode (unless a Distributed Energy Resource Aggregator asset is registered as a Demand Response Resource – Type I, which currently allows aggregation in a single Local Balancing Authority Area)
(2.) Focus on Electric Storage Resource and Dispatchable Intermittent Resource types to accommodate the 0.1 MW (or smaller) minimum required by O2222
While the presentation at the DERTF on 3/8/2011 titled “Order 2222 Evaluation Framework” (agenda item 05) provided a nice summary of the basis for these proposals, we note that we found the information provided in the preceding presentation, “DER Research Insights” (agenda item 04), to provide key support for the summary. In addition, while WPPI can appreciate that DERAs may be interested in amassing an asset over an area larger than a single EPNode, the proposed limitation facilitates not only accurate pricing of DERA transactions in the MISO market but also the accurate pricing of the local distribution utility’s energy purchases from the MISO market.
The recommendation to develop pilot projects to evaluate DER integration and aggregation at the distribution level in multiple settings and combinations could be quite helpful and useful if properly planned and timely executed. A key part of that proper planning and execution, of course, would be express reference to MISO experience to date with DR and storage as well as experience with a wider range of DERs in other regujlatory contexts and jurisidictions. There is also a growing body of published academic and industry research which would be useful in planning and executing an optimum portfolio of such pilot projects. And, of course, continuing stakeholder input in that process would be essential.
DTE appreciates this opportunity to provide feedback on MISO’s evaluation framework. DTE is happy to discuss and/or clarify this feedback either through stakeholder forums or through other discussions with MISO.
MISO’s recommendation to use a single EP Node approach for the geographic scope of aggregations
MISO’s recommendation to use a single EP Node as the scope of DER aggregations seems prudent given the technical challenges associated with broader aggregations. In its order, FERC did not mandate a multi-node approach and instead left this decision to the ISOs to determine a technically feasible approach. The 100 kW threshold that FERC specified in its order also helps to ensure the adoption of single node aggregations won’t present an undue barrier to DER market participation. DTE is looking at how MISO’s EP Nodes map to its distribution system and may provide additional feedback as the operational impacts become clearer.
MISO’s recommendation to use the Dispatchable Intermittent Resource (DIR) and Energy Storage Resource (ESR) participation models as a starting point for the Order 2222 DERA model
DTE believes that MISO’s decision to start with the DIR and ESR participation models is reasonable, but agrees with the comments shared by MPSC Staff that MISO should provide more documentation to support its recommendations beyond the color-coded boxes in its scoring rubric. DTE also recognizes the complexity associated with accurately committing resources smaller than 1 MW in the time allowed for MISO to operate its market. Given that MISO has suggested it may need to bifurcate its commitment of DER aggregations between those smaller than 1 MW and those larger than 1 MW, MISO should clarify whether it will need to develop two participation models (the Order-2222-compliant DIR and ESR models) or four participation models (the Order-2222-compliant DIR and ESR models, each with sub-participation models for resources less than 1 MW and resources 1 MW or greater).
Alcoa Power Generating Inc. (APGI)
Comments On
MISO Demand Response Task Force (DERFT)
“Initial Evaluation Results (IR070)”
March 22, 2021
During the March 8, 2021 meeting of the Distributed Energy Resource Task Force (DERTF), MISO requested feedback on the Initial Evaluation Results related to Order 2222 Evaluation Framework.
As a long time, provider of Demand Response Resources in the MISO Energy and Ancillary Services Market and a MISO member, APGI respectfully submits the following feedback to the DERTF and MISO Staff:
Overall Evaluation Framework: The general design presented by MISO Staff for the evaluation framework is both simple and easy to compare how various options ranked in MISO’s evaluation of the compliance elements. The general framework should serve well as a high-level overview of options.
However, APGI would request that MISO provide more detail on what went into the various color assignments. Why is one item light green and another dark green? An explanation in the following slides would help with understanding the path that MISO is proposing. More explanation on how the option impacts Grid Reliability and Resiliency, as well as Market Efficiency would be helpful. What are the pros/cons of the various options under consideration?
Also, is there an evaluation metric that should be added relative to the enabling of DERAs? For example, a solution may be “Green” or easy for MISO to implement but a “Red Flag” for DERA implementation, because it is very limiting to DERAs. The current framework is very MISO centric and does not appear to consider how the option helps facilitate DER integration.
Finally, the two items, Solution Complexity and Implementation Costs seem to be highly correlated to the point that perhaps they could be the same evaluation metric.
Participation Model: APGI has been a MISO Market Participant with both DRR Type I and DRR Type II resources for over a decade. In examining the potential models for DER participation, APGI would suggest that MISO should closely examine either the modification of current models or the creation of a new model that allows for both the reduction of load and injection of energy from the same asset. This has been a significant barrier to participation for some entities like APGI.
For example, a location with a storage capability that exceeds its operational demand could be offered into the MISO market to first reduce demand on the system (traditional DR) and then, as the battery continues to discharge, become a net injection of energy into the MISO system. Currently, the MISO participation models do not allow for a single resource to effectively offset load and inject into the market. This “one or the other” modeling issue has been a major barrier to participation of APGI resources for over a decade and has led to significant localized market inefficiencies because of the inability to model injections from behind the meter resources. Aggregations of DER would face some of these same issues under the existing MISO models.
Because of the opportunity to create a new (or modify an existing) participation model in MISO, APGI strongly suggests MISO investigate the option of having an aggregated resource that can both reduce demand and inject into the market. In the current evaluation framework, it does not appear that MISO even considered the option of creating a new type of market resource and APGI would request MISO include that option in its evaluation.
As always, APGI appreciates the opportunity to provide feedback on these issues.
If there are any questions or comments, please feel free to reach out to:
Steve Dowell
Alcoa Power Generating Inc.
(812) 842-3377
DeWayne Todd
DDT LLC
(812) 573-8052
MISO recommends a focus on DIR and ESR participation models at 0.1 MW, but leaves out consideration of DRR Type I and DRR Type II being able to participate at 0.1 MW. Seems like this would not lead to a comprehensive compliance filing with FERC Order 2222, since these DRR classifications would still not meet the minimum threshold of 0.1 MW required by O2222. Is MISO's intent with this proposal to make DIR and ESR the 1st priority, while addressing DRR Type I and Type II in a later 2nd priority effort? Or is MISO's intent to leave the DRR limits as-is with no plan to lower the present 1.0 MW participation threshold? We would recommend that DRR Type I and DRR Type II need to have their minimum participation limit lowered to 0.1 MW in order for MISO to be fully compliant with O2222. If that can be addressed in a 2nd priority effort, MISO should include that in a workplan schedule shared with stakeholders to affirm that DRR participation thresholds will be addressed eventually.